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Albrecht v. United States

Ms. Albrecht, age 83, transferred a significant number of shares of Beneficial Finance Company to her family members and died within three years.

Under then current estate tax law, any gift transfer made within three years of the donor’s death was presumed to be given by the decedent “in contemplation of death” and estate taxes unless the decedent’s estate could prove the contrary.  Mrs. Albrecht’s estate contended that Mrs. Albrecht had no thought of dying but instead purchased new clothes and was seen dancing with Ted Lewis in a Springfield, Illinois, nightclub during the three-year period.  No. T-2900 (D. Ill. 1966).

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